Why Estate Agents Need to Verify Your Identity When You Buy or Sell a Home

Buying or selling a property involves large sums of money, several professional organisations and important legal responsibilities.

For that reason, your estate agent will ask for evidence confirming who you are, where you live and, when you are purchasing, how the transaction will be funded.

These requests are not optional administration introduced by the agent. Estate agency businesses are regulated under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, as amended. HMRC’s current guidance, updated in July 2026, requires estate agents to identify their customers, verify their identities, assess the risk connected with each relationship and retain appropriate records.

At Integra Estates, we explain what information is needed, why it is required and when the checks must be completed.

Our aim is to make the process secure and straightforward while protecting our clients, the transaction and the integrity of the property market.

The straightforward answer

Estate agents need to verify your identity because the law requires them to know who their customers are.

This normally involves confirming:

• Your full legal name.

• Your date of birth.

• Your current residential address.

• That your identification document is genuine.

• That you are the person shown on the document.

• That a seller owns the property or has authority to act.

• How a buyer intends to finance the purchase.

• Whether anybody else is acting for or funding the customer.

• Whether additional checks are required because of the circumstances or assessed risk.

The exact checks may differ between customers. Anti money laundering compliance is risk based, which means the agent must consider the individual, the property, the proposed transaction, the source of funds and any relevant geographical or delivery risks.

Being asked for additional information does not mean that you are suspected of wrongdoing.

It means the estate agent is carrying out the checks required for that particular transaction.

What is customer due diligence?

The formal term for these checks is customer due diligence, often shortened to CDD. It is also sometimes described as knowing your customer.

Customer due diligence includes more than looking briefly at a passport.

An estate agent must take reasonable steps to:

• Identify every customer.

• Verify each customer’s identity using reliable and independent information.

• Identify any beneficial owner where somebody else ultimately owns or controls the customer.

• verify anybody claiming to act for another person.

• Confirm that the representative has authority to act.

• Understand the purpose and intended nature of the business relationship.

• Assess the money laundering, terrorist financing and proliferation financing risk.

• Monitor the relationship and update information when necessary.

• Consider the source and origin of funds on a risk based basis.

• Retain evidence of the checks and decisions made.

HMRC requires the extent of the checks to be proportionate to the risk and sufficient for the agency to demonstrate that it understands who its customers are.

Why estate agents are included within the regulations

Estate agents do not usually handle the money used to purchase a property.

They do, however, bring sellers and buyers together, receive information about the proposed purchase and become involved at an early stage of the transaction. This places them in a useful position to identify unusual ownership arrangements, unexplained funding, impersonation or behaviour that does not fit the apparent purpose of the transaction.

Property transactions can involve:

• Substantial sums of money.

• Companies, trusts and overseas structures.

• Gifts and third party funding.

• Buyers purchasing without a mortgage.

• Representatives acting for owners or purchasers.

• Property being transferred between connected people.

• Funds arriving from several different accounts.

• Sudden changes to the proposed buyer or funding arrangements.

Most of these situations have entirely legitimate explanations.

The estate agent’s responsibility is to understand and record that explanation rather than make assumptions.

Do sellers need to complete identity checks?

Yes.

The seller is the estate agent’s customer and must be identified and verified.

HMRC’s current estate agency guidance says that the business relationship with a seller begins when an agreement is made or a contract is signed with the agent, before the property is marketed. The required identity verification must therefore be completed before that business relationship is established.

At Integra Estates, a property is not placed on the market until the required seller onboarding has been completed and approved.

This normally includes:

• Valid photographic identification.

• Proof of the current residential address dated within the previous 90 days.

• Digital identity verification.

• A biometric identity check where required by our procedure.

• Politically exposed person and sanctions screening.

• Confirmation of the legal owners.

• Evidence of authority where somebody acts for an owner.

• A completed individual client risk assessment.

• The relevant client declarations and seller documentation.

• Written approval through our internal anti money laundering process.

This protects the true owner of the property and reduces the risk of an agent marketing a home upon fraudulent, incomplete or unauthorised instructions.

How does the estate agent confirm that a seller owns the property?

Identification confirms who the seller is. It does not, by itself, prove that the person owns the property.

The estate agent will normally compare the seller’s information with the registered title held by HM Land Registry.

Where the names do not match, further evidence may be needed.

This can happen for entirely ordinary reasons, including:

• Marriage or divorce.

• A formal change of name.

• The death of a registered owner.

• An outdated address on the title.

• The property being held within a trust.

• An attorney acting under a power of attorney.

• Executors dealing with a probate estate.

• A company owning the property.

• A restriction appearing on the title.

• A property that remains unregistered.

Where somebody acts for the owner, the agent must identify that person, verify their identity and establish that they are genuinely authorised to give instructions. HMRC’s guidance specifically requires checks on representatives as well as the underlying customer.

Legal questions concerning ownership or authority should be referred to the seller’s conveyancer.

Do buyers need to complete checks as well?

Yes.

The buyer also becomes a customer of the estate agent for anti money laundering purposes.

HMRC recommends beginning buyer due diligence as soon as reasonably possible after first contact. Current guidance says the checks should be completed early enough to avoid wasted costs and delays and, at the latest, before the relevant business relationship is established.

At Integra Estates, we ask buyers to complete their checks promptly after an offer is agreed.

We do not issue the Memorandum of Sale until the required identification, funding information, individual risk assessment and internal approval have been completed.

The buyer may be asked for:

• Valid photographic identification.

• Proof of their current residential address.

• Digital and biometric identity verification.

• Politically exposed person and sanctions screening.

• A mortgage agreement in principle where finance is required.

• Evidence of available deposit funds.

• Evidence that an existing property is under offer where the purchase depends upon its sale.

• An explanation of the source of funds.

• Information concerning a gifted deposit or third party contribution.

• Employment, income or wider financial information where relevant.

The checks are completed separately for every buyer. One person passing verification does not automatically verify a spouse, partner, relative or company purchasing with them.

Can an estate agent accept an offer before the buyer has completed every check?

An estate agent must communicate offers to the seller in accordance with its professional obligations.

That does not mean the agent can progress indefinitely without completing the buyer’s due diligence.

Integra Estates begins the checks at an early stage and will not issue the Memorandum of Sale until the required process has been completed.

Starting promptly protects both parties. It reduces the likelihood of the seller removing the property from the market only to discover later that the buyer cannot provide the required information.

Which identity documents are normally accepted?

A valid passport or photographic driving licence will commonly be used as evidence of identity.

Other documents may sometimes be accepted depending upon the person’s nationality, circumstances and the verification method being used.

The document should normally:

• Be current and valid.

• Show the person’s full name.

• Include a recognisable photograph.

• Show the date of birth.

• Be sufficiently clear for verification.

• Show no sign of alteration or damage that prevents reliable checking.

A photograph of a document may not be enough on its own.

The estate agent must also obtain reasonable assurance that the document belongs to the person presenting it.

What can be used as proof of address?

Proof of address must show the person’s name and current residential address.

Integra Estates normally asks for a document issued within the previous 90 days, such as:

• A bank or building society statement.

• A utility bill.

• A council tax statement or letter.

• Official correspondence from a government department.

• Another reliable document accepted through our verification procedure.

A mobile telephone bill or document sent to a business address may not provide sufficient evidence of the person’s residential address.

Where somebody has moved recently or receives all correspondence digitally, alternative evidence may be considered.

The important point is to speak to us rather than submitting documents that do not reflect your current circumstances.

Why does Integra Estates use digital identity verification?

Integra Estates uses Veriphy to support its digital identity checking process.

Digital verification can compare identity information with reliable electronic sources and may include a facial or biometric check to establish that the person completing the process matches the identification document.

Government guidance published in February 2026 confirms that appropriately certified digital identity services can form part of customer due diligence under the Money Laundering Regulations. Digital identity may involve passport or driving licence information, address information and biometric checks such as a facial scan.

Technology supports the decision. It does not remove Integra Estates’ responsibility to assess the result and consider whether further information is required.

What happens during a biometric identity check?

The customer will normally receive a secure verification request and follow the instructions using a mobile telephone or compatible device.

The process may ask the person to:

• Photograph their identification document.

• Allow the system to read the document details.

• Take a live image or short facial scan.

• Complete a movement or liveness check.

• Confirm their current information.

The purpose is to reduce the risk of somebody using another person’s document or presenting a copied or manipulated image.

Biometric information used to identify someone receives additional protection under data protection law. Organisations using it must identify an appropriate legal basis, apply relevant safeguards and handle the information in accordance with the wider UK GDPR principles.

What happens if the digital check does not pass?

An unsuccessful electronic result does not prove that the person has done anything wrong.

A check may be unable to verify somebody because:

• They have moved recently.

• Their current address is not yet reflected across electronic sources.

• They have a limited UK credit or electoral history.

• Their name appears differently on separate records.

• A document image is unclear.

• The document has expired.

• The facial image could not be matched reliably.

• The person has recently arrived in the United Kingdom.

• Their records are held primarily overseas.

• The system requires further information.

Integra Estates may ask for alternative documents, clarification or a video call so that the individual can be compared with their photographic identification.

The matter is assessed by a person rather than decided solely by an automated result.

What is a politically exposed person?

A politically exposed person, commonly known as a PEP, is somebody who holds or has held a prominent public function.

The definition can also extend to certain family members and known close associates.

Being identified as a PEP does not mean that the individual has committed an offence or is suspected of dishonesty.

The regulations require additional due diligence because certain prominent roles can create greater exposure to bribery, corruption or misuse of public funds.

HMRC’s 2026 guidance explains that domestic PEPs should normally begin from a lower risk position than non domestic PEPs unless other risk factors are present. Non domestic PEPs must be treated as higher risk, with enhanced checks applied.

Additional information may include:

• The nature of the person’s public role.

• The origin of their overall wealth.

• The source of the money being used.

• Approval from senior management.

• More frequent monitoring of the relationship.

A PEP match must be considered carefully because people may share the same or a similar name.

Why are sanctions checks carried out?

Financial sanctions restrict dealings with designated individuals, organisations and entities.

Estate agents must consider whether there is any legal barrier to entering into a business relationship with a person. Government digital identity guidance expressly identifies sanctions as one of the matters that regulated businesses may need to assess during customer due diligence.

A potential name match does not automatically mean that the customer is sanctioned.

Further checks may be needed to compare:

• Full names.

• Dates of birth.

• Nationality.

• Addresses.

• Other identifying information.

The purpose is to establish whether the result relates to the client or to another person with a similar name.

What is proof of funds?

Proof of funds demonstrates that a buyer has access to enough money to proceed with the proposed purchase.

It may include:

• A mortgage agreement in principle.

• A recent bank or savings statement.

• Evidence of investments being used.

• Confirmation that another property is sold subject to contract.

• Evidence of equity expected from a related sale.

• A gifted deposit letter and supporting information.

• Evidence of inheritance or another legitimate receipt.

• Company funding information where a business is purchasing.

Sensitive information that is not relevant can often be obscured, but the buyer should not remove details needed to establish ownership of the account, available funds or their origin.

Proof of funds and source of funds are different

These terms are often confused.

Proof of funds shows that the money exists and is available.

Source of funds explains where the money being used for the particular transaction came from.

Examples of source of funds include:

• Personal savings accumulated from employment.

• Proceeds from the sale of another property.

• A mortgage.

• An inheritance.

• A gift from a family member.

• The sale of investments.

• A business dividend.

• Compensation or an insurance payment.

Source of wealth is broader. It describes how the person acquired their overall wealth over time.

HMRC’s current guidance requires estate agents to monitor business relationships and, where appropriate, understand and verify the source and origin of the money involved. Source of funds and source of wealth verification is specifically required in certain enhanced due diligence situations, including relevant PEP relationships and connections with particular higher risk jurisdictions.

Why might employment or income information be requested?

Employment information can help explain how savings or a deposit have been accumulated.

For example, a deposit built gradually from salary may be supported by employment information and account history.

The estate agent is not carrying out the lender’s affordability assessment. The purpose is to understand whether the proposed funding is consistent with the information provided and the assessed level of risk.

Where the funding has come from another source, the customer should explain that source accurately rather than trying to make it fit an employment explanation.

What happens with a gifted deposit?

A gifted deposit is common, particularly where parents or relatives assist a buyer.

The buyer may be asked to provide:

• The donor’s name.

• Their relationship to the buyer.

• The amount being given.

• Confirmation that the money is a gift rather than a loan.

• Evidence showing where the donor obtained the money.

• Evidence that the funds have been or will be transferred.

• Further identity or address information where the risk assessment requires it.

The buyer’s conveyancer and mortgage lender are likely to conduct their own checks as well.

The same information may therefore be requested by more than one regulated organisation. Each business remains responsible for satisfying its own obligations.

Does a cash buyer still need checks?

Yes.

In property, the term cash buyer usually means that the purchaser does not require a mortgage. It does not mean that the purchase will be made using banknotes.

A purchase without mortgage finance may require closer examination of the source of the purchase money because there is no lender carrying out its own financial checks.

HMRC advises estate agents to take particular care where a purchase does not involve a mortgage and to consider whether the source of funds is consistent with the customer’s known circumstances.

Integra Estates does not accept cash payments. Any fee payable to us must be paid directly to the company’s business bank account.

What checks apply to companies and trusts?

Where a company, partnership, trust or similar arrangement is involved, checking one representative is not enough.

The estate agent may need to establish:

• The organisation’s legal name.

• Its registration details.

• Its registered address.

• Its directors or equivalent controlling individuals.

• The ownership and control structure.

• The beneficial owners.

• The identity of the person giving instructions.

• Their authority to act.

• The intended purpose of the transaction.

• The source of the company or trust funds.

HMRC requires regulated businesses to understand the ownership and control structure of legal entities and take reasonable steps to identify and verify their beneficial owners.

More complex ownership does not automatically mean that a transaction is suspicious.

It does mean that the agent must understand who ultimately controls the organisation and benefits from the transaction.

What happens with probate sales and powers of attorney?

Where somebody acts for another person or an estate, Integra Estates must verify both the representative and the legal authority allowing them to act.

Depending upon the circumstances, this may involve:

• A grant of probate.

• Letters of administration.

• A lasting or enduring power of attorney.

• A court order.

• Trust documentation.

• Company authority.

• Identification for executors, attorneys or trustees.

• Confirmation of the underlying owners or beneficiaries where required.

A family relationship does not remove the need to establish legal authority.

Our probate property service provides practical property support for executors and families while legal advice remains with the estate’s solicitor or probate practitioner.

Why might checks need to be repeated?

Passing an identity check once does not necessarily mean that no further information will ever be required.

Estate agents must keep customer information under review and conduct ongoing monitoring throughout the business relationship.

Further checks may become necessary where:

• Identification expires.

• The customer changes address.

• A different person joins the purchase.

• A representative begins acting for the customer.

• The funding method changes.

• A gifted deposit is introduced.

• Funds arrive from another country or account.

• The proposed purchaser changes from an individual to a company.

• The transaction becomes materially different.

• New information changes the risk assessment.

HMRC requires customer information and risk assessments to be updated when circumstances change.

A request for updated information should not be interpreted as an accusation. It reflects the agent’s continuing legal responsibility.

What happens if the required information is not provided?

Where an estate agent cannot complete the required customer due diligence, it cannot establish or continue the relevant business relationship.

HMRC guidance requires the business to refrain from proceeding, terminate an existing relationship where necessary and consider whether a Suspicious Activity Report is required.

At Integra Estates:

• A seller’s property will not be listed until the required onboarding is complete.

• A buyer’s Memorandum of Sale will not be issued until the required checks and funding information have been approved.

• Every individual is assessed separately.

• Additional information will be requested where the circumstances require it.

• The business relationship will not proceed without the required approval.

A refusal to provide documents does not automatically establish wrongdoing.

It does mean that we are unable to continue.

Can Integra Estates tell me whether a report has been made?

There are circumstances in which an estate agent may be prohibited from revealing details of its internal anti money laundering decisions.

The law contains offences relating to the inappropriate disclosure of information that could prejudice an investigation, commonly referred to as tipping off. Estate agents must therefore be careful about what they communicate where a suspicion has arisen.

This does not affect our commitment to explain ordinary document requests and verification procedures as clearly as possible.

How Integra Estates protects your personal information

Identity documents, financial information and biometric verification data are sensitive.

They must be collected for a clear purpose, limited to what is reasonably necessary, handled securely and retained for no longer than required.

The UK GDPR principles include lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, security and accountability.

Integra Estates uses its verification and compliance systems for the purpose of meeting legal and regulatory responsibilities.

Customers should:

• Use only the verification link supplied directly by Integra Estates.

• Check the sender before opening or uploading anything.

• Contact us using the telephone number published on our website where they are uncertain.

• Avoid sending identity or bank documents through an unexpected message.

• Never provide passwords, security codes or online banking login details.

A legitimate anti money laundering check does not require access to your online banking password.

How long are the records kept?

Current HMRC estate agency guidance requires customer due diligence records to be retained for five years after the relevant business relationship ends.

The records should then be deleted unless another lawful reason requires them to be retained.

For a seller, the business relationship normally ends when the transaction completes or the marketing agreement ends.

For a buyer, it normally ends when the purchase completes or the accepted offer is withdrawn or cancelled.

The five year retention period allows the agency to demonstrate what checks were completed and why particular compliance decisions were made.

Why might my solicitor, lender and estate agent ask for the same information?

Estate agents, conveyancers, mortgage lenders and other regulated businesses have their own legal responsibilities.

One organisation completing a check does not automatically remove the obligation placed upon another.

The precise information may also be used for different purposes.

For example:

• The estate agent assesses the customer and property transaction risk.

• The lender considers mortgage suitability, affordability and security.

• The conveyancer examines the legal transaction and movement of funds.

• A financial adviser assesses the proposed mortgage or investment.

The Government intends to reduce unnecessary duplication through future improvements to digital identity and property transactions, but each regulated business must continue satisfying the rules currently applying to it.

Are compliant estate agents registered with HMRC?

Estate agency businesses within the scope of the Money Laundering Regulations must register with HMRC for anti money laundering supervision unless another appropriate supervisor applies.

Members of the public can check the HMRC Supervised Business Register.

Registration does not mean that HMRC endorses every service or valuation provided by the agent.

It confirms that the business is registered within the relevant supervisory framework.

A homeowner should also consider the agent’s redress scheme membership, contract, valuation evidence, communication and wider professional standards.

What happens when an estate agency does not comply?

HMRC can impose financial penalties for failures involving customer due diligence, registration, risk assessments, record keeping and the required policies, controls and procedures.

Serious breaches can result in prosecution. HMRC also publishes information concerning businesses that have received certain penalties, and registrations may be suspended or cancelled.

The purpose of compliance should not be fear of a penalty alone.

Proper procedures protect customers, staff, the agency and the wider property transaction.

Integra Estates’ anti money laundering process

Integra Estates applies the same underlying standards to every client, regardless of who they are, how they were introduced or the value of the property.

Our process is built around several principles.

Every person is checked individually

Joint owners, joint purchasers and representatives are not treated as one customer.

Each relevant individual must complete the checks applying to their role.

Sellers are verified before marketing

We do not list a property until the seller’s identity, address, ownership position, required documents and individual risk assessment have been completed and approved.

Buyers are verified before the Memorandum of Sale

We establish the buyer’s identity, proposed funding, relevant financial position and assessed risk before issuing the sales memorandum.

Digital verification supports human review

Veriphy helps us verify identity and screen relevant information. Any result requiring further investigation is considered by a person.

The source of funds must make sense

We consider how the proposed purchase will be financed and request supporting evidence where appropriate.

Suspicion is reported internally

Every member of the Integra Estates team has a responsibility to report a concern to the Money Laundering Reporting Officer.

The final decision rests with the MLRO

Thomas Bailey, Director and Money Laundering Reporting Officer, is responsible for the final internal review and approval where required.

No cash is accepted

Payments to Integra Estates must be made directly into the company’s business bank account.

These controls are intended to make our service consistent, defensible and fair.

Areas supported by Integra Estates

Integra Estates supports buyers and sellers across the following 32 focus areas:

Beckenham, Brockley, Catford, Dulwich, Forest Hill, Kennington, Peckham and Sydenham

Bermondsey, Bromley, Chislehurst, Dulwich Village, Greenwich, Ladywell, Rotherhithe and Waterloo

Blackheath, Camberwell, Croydon, East Dulwich, Hayes, Lee, Southwark and West Dulwich

Borough, Canada Water, Crystal Palace, Elephant and Castle, Hither Green, Lewisham, Surrey Quays and West Wickham

The legal duties do not change because of the area, property price or client relationship.

A seller in Beckenham, a first time buyer in Catford and a company purchasing an apartment in Canada Water must all be assessed according to their individual circumstances.

Frequently asked questions

Why does my estate agent need my identification?

Estate agents are legally required to identify and verify their customers under the Money Laundering Regulations.

The checks help establish that the customer is who they claim to be and that the agent understands the people involved in the transaction.

Do sellers need to provide identification?

Yes.

The estate agent must identify the seller, verify their identity and establish that they own the property or have authority to act for the owner.

When will Integra Estates ask for my documents?

Sellers are asked to complete the process before the property is listed.

Buyers are asked to complete it promptly when progressing an offer and before Integra Estates issues the Memorandum of Sale.

Can somebody else complete the verification for me?

No.

Every relevant person must be identified individually.

Where somebody is acting as your attorney, executor, trustee or authorised representative, we must verify that person and establish their authority as well as considering the underlying customer or owner.

I have known the estate agent for years. Do I still need checks?

Yes.

Personal familiarity does not remove the agency’s legal responsibilities. HMRC expects customer due diligence to be completed even where the business knew the person before they became a customer, unless valid previous verification remains suitable and current.

I completed checks during an earlier transaction. Must I do them again?

Possibly.

The agency must consider whether the previous information remains accurate, current and appropriate for the new transaction.

Changes to your address, identification, funding or circumstances may require refreshed checks.

Does a digital verification result make the decision automatically?

No.

Digital verification provides evidence and screening information. Integra Estates remains responsible for considering the result, the wider transaction and any need for additional information.

Why do you need proof of funds before issuing the Memorandum of Sale?

It helps establish that the buyer has a credible means of proceeding and allows us to understand how the proposed purchase will be financed.

It also reduces the risk of a seller beginning the legal process without adequate information about the buyer’s funding position.

Is being a cash buyer suspicious?

No.

Many purchases without mortgages are entirely legitimate.

The source of the funds still needs to be understood and may require additional evidence because no mortgage lender is involved.

What if my parents are providing the deposit?

Tell us from the beginning.

We may need information confirming the amount, the donor, the relationship and the source of the gifted money. The lender and conveyancer are also likely to request evidence.

What happens if my name is different on the property title?

Explain the reason and provide the supporting document where available.

A marriage certificate, deed poll, divorce documentation or other evidence may resolve the difference. Your conveyancer should advise on any title amendment required.

Is my information used for marketing?

Personal information collected for anti money laundering compliance must be used according to the stated lawful purpose and applicable data protection requirements.

Your privacy information should explain how personal data is collected, used, shared and retained.

How long will Integra Estates keep my documents?

Customer due diligence records are normally retained for five years after the relevant business relationship ends, in accordance with the Money Laundering Regulations and HMRC guidance.

What happens if I refuse to provide identification?

Integra Estates will be unable to establish or continue the business relationship.

A property will not be listed and a buyer’s Memorandum of Sale will not be issued without the required checks and approval.

Will my solicitor still check my identity?

Yes.

Solicitors and conveyancers have their own professional and regulatory obligations and may need to repeat or extend the checks.

Buying or selling a property?

Identification checks are a normal and necessary part of a properly managed property transaction.

Completing them promptly allows Integra Estates to establish the correct owners, understand the buyer’s funding and progress the transaction without avoidable uncertainty.

We will tell you what is needed, explain the reason for the request and provide a secure route for completing the process.

You can learn more about why Integra Estates places honesty and integrity at the centre of its service or meet the Integra Estates team.

Speak to Integra Estates about your property move

Telephone: 0203 870 00 00

Email: [email protected]

This article provides general information about anti money laundering checks applying to estate agency work in the United Kingdom. It does not constitute legal or financial advice. Requirements may differ according to the customer, transaction and assessed risk.